1.2 We process your Personal Data in accordance with the DPL. We process your Personal Data as required for the performance of your agreement(s) with us to use our services ("Services"), operating any account maintained with us, accessing the online platform operated by us (which is accessible through our website at www.stashaway.ae or through our mobile application) ("Platform"), websites or mobile applications, or otherwise to enable you to provideinformation to or communicate with us. We undertake the processing of your Personal Data as required to comply with Applicable Law (as defined below) that we are subject to. We also process your Personal Data for the purpose of legitimate interests pursued by us or a third party to whom your Personal Data is made available, except in the circumstances where such interests are overridden by your interests or rights as a data subject under the DPL. Please see clause 5 below for a detailed list of the “Purposes” for which we process your Personal Data.
1.4 The words "we", "us", "our" or any of their derivatives refer to Stashaway and its successors and any novatee, assignee, transferee or purchaser of Stashaway's rights and/or obligations hereunder and any reference to Stashaway includes a reference to such successor, novatee, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
2.2 The Personal Data that we collect or may collect include:
Section 2 sets out the type of Personal Data that we collect or may collect from you.
3.1 The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
Section 3 sets out where we may obtain Personal Data from.
4.1 The accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data.
4.2 We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any Applicable Law (including the DPL).
As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data.
5.1 We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes, the following purposes ("Purposes"):
Section 5 sets out how we may use your Personal Data. This includes using your Personal Data for the provision of our Services / Platform to you, for marketing purposes, and to comply with regulatory requirements.
6.1 We may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in DIFC, Singapore or otherwise, to carry out the Purposes. This includes, disclosing and sharing your Personal Data with the following:
We may also disclose and share your Personal Data with other persons in connection with the Purposes described in Section 5.
7.1 You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please click on the “Unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer at email@example.com.
7.2 You may also withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the Purposes described in Section 5 by submitting your request in writing or via email to our Data Protection Officer.
7.3 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
7.4 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Section 7.2 above.
7.5 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
You have the right to withdraw any consent provided by you to receive any marketing information from us or to the collection, usage and/or disclosure of your personal data in connection with the Purposes described in Section 5. We will seek to process your withdrawal request within ten (10) business days. However, a withdrawal of your consent to collect, use and/or disclosure your personal data in connection with the Purposes described in Section 5 means that we may not be able to continue to provide you with our Services.
We may transfer, store, process and/or deal with your Personal Data outside the DIFC for one or more of the Purposes set out above. In doing so, we will comply with the DPL and other applicable data protection and privacy laws.
WWe may transfer your Personal Data outside the DIFC. If we do, we will comply with applicable data protection and privacy laws.
We may retain your Personal Data for as long as it is necessary for the purpose it was collected, for business purposes or to comply with applicable laws.
10.1 To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
10.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
We have introduced administrative, physical and technical measures to ensure the protection of your Personal Data with us.
You have a number of key rights under the DPL. We have set these out below:
11.1 You may also request access to Personal Data we hold, or request the rectification of any inaccurate data. If you would like to do so, please contact our Data Protection Officer at firstname.lastname@example.org.
11.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
11.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the DPL).
You may contact our Data Protection Officer to access or request changes to your Personal Data.
12.2 A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our web site but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the web site.
12.3 You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your web site visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our web sites or the Platform.
12.4 We also use analytics programs such as Google Analytics for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Features of Google Analytics that we may use include Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Accordingly, your Personal Data may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience. You may refer to this link for more information about how your Personal Data is collected through Google Analytics.
12.5 We and our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support nor endorse the goals, causes or statements of these websites or mobile applications which display our ads.
12.6 Using the Google Ad Settings, you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available at this link. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences.
If you have any questions about any aspects of this policy or your Personal Data, please contact our Data Protection Officer at email@example.com or +971 4 590 999.
StashAway Management (DIFC) Limited is regulated by the DFSA (license number F006312) for the provision of arranging custody, arranging deals in investments, advising on financial products, and managing assets, with a retail endorsement.
StashAway Management (DIFC) Limited (registration number CL 3982) is established in the DIFC pursuant to the DIFC Companies Law. Its registered address is Unit 1301, Level 13, Emirates Financial Towers, P.O. Box 507051, Dubai International Financial Centre, Dubai, United Arab Emirates.